Inside Police Custody 2 any contextual information, nor specify how the measures reflect each aspect of the relevant Directive. It was clear that in some countries in the study, considerable effort had been made to ensure that the provisions of the Directives were transposed, at least as far as laws and regulations were concerned. However, this was not the case in other countries, and in all of the countries there were examples of failures to adequately transpose certain provisions, for example: failure to impose a requirement to take into account the particular needs of vulnerable suspects or accused persons when informing them of their procedural rights; no explicit provision that a detained suspect be allowed to keep the letter of rights throughout their detention; limitations on free interpretation of lawyer/client consultations; no provisions designed to guarantee the competence of interpreters; power to derogate from the right of access to a lawyer outside of the circumstance prescribed by the Directive. The countries of greatest concern, with regard to transposition of the Directives, are Bulgaria and Romania. The three Directives which are the subject of this study are all expressed to apply to persons from the time that they are made aware by the competent authorities, by official notification or otherwise, that they are suspected or accused of having committed a criminal offence. The official view adopted in Bulgaria is that the initial 24-hour period of police detention is an administrative procedure, and that therefore the Directives do not apply. In Romania, the police have power to take a person to a police station prior to formal arrest and this, similarly, is treated as an administrative procedure which does not attract the protections afforded by the Directives. Thus, the Directives are deemed not to apply to persons who are, de facto, arrested or detained. However, even if the relevant laws faithfully reflect the requirements of the Directives, this is not sufficient to ensure that procedural rights are respected in practice. In respect of the right to interpretation and translation, procedures for determining the need for interpretation were inadequate in all of the countries in the study. Whilst the letter of rights was available in a range of languages in a minority of countries, this was not the case in the majority, and since prompt access to an interpreter was often not possible, many suspects who did not speak or understand the relevant language were not informed of their procedural rights in a language that they understood. Mechanisms for ensuring that competent interpreters were available to interpret at police stations were often found to be either non-existent or inadequate, a state of affairs that was contributed to by the lack of a robust national register of interpreters, and low levels of remuneration. The law in most of the countries in the study regulates, with some degree of precision, the time at which information about procedural rights must be provided to suspected and accused persons, and in most cases, this is sufficient to comply with the requirements of the Directive on the right to information. However, in many of the countries, the letter of rights does not cover all of the rights required by the Directive, and whilst most countries have a standard letter of rights, it was found to be lengthy and complex in all of them, so that many suspected and accused persons, particularly those with vulnerabilities or those who have language difficulties, are unable to fully understand them. The laws of many of the countries do not require that detained suspects be allowed to keep the letter of rights in their possession, but even in those that do, this is often not permitted in practice. Oral information about procedural rights is often provided in a formalistic way, and in some countries the evidence suggests that the police discourage suspects from exercising their procedural rights, and in some cases, even prevent them from doing so. Perhaps the greatest difficulties disclosed by the research concern the right of access to a lawyer. Generally, the laws of all of the countries in the study provide for such a right (subject to the limitations already explained in respect of Bulgaria and Romania) but, with the exception of a minority of counties, most detained suspects in most countries do not, in practice, have access to a lawyer at the early stages 5